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PUC Rejects Most Retail Market Enhancements

Endorses Seamless Moves, But Implementation Plan, Cost Recovery, Responsibility Left An Open Question

February 8, 2018

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The Public Utilities Commission of Ohio issued an order declining to adopt most recent market enhancements studied in a working group, but did order the filing of a plan to implement seamless moves

In Ohio, a seamless move allows a customer to transfer an existing CRES contract to a new address, if the customer and CRES provider both consent to the transfer of the contract. The customer would receive generation service from the CRES provider on the first day of service at the new address.

"The Commission finds that a seamless move mechanism should be adopted as a Statewide standard. Seamless move creates an appropriate balance. In theory, seamless move reduces the burden of the already shopping customer by allowing for an already negotiated CRES contract to be moved to the customer's new address, but at the same time, unlike contract portability, seamless move requires that the customer affirmatively choose that opportunity when calling the EDU to transfer service," PUCO said

"At the same time, the Commission recognizes that the MDWG [Market Development Working Group] did not work through the details of seamless move implementation within each EDU footprint. Not only this, but cost allocation for implementation of a seamless move mechanism has not been fully vetted by the MDWG. Therefore, within the next six months of this Finding and Order, RESA and each EDU should work together to file an operational plan for implementation of a seamless move mechanism for Staff review and approval," PUCO said

PUCO specifically ordered that, "within the next six months of this Finding and Order, RESA and each EDU should work together to file an operational plan for implementation of a seamless move mechanism for Staff review and approval."

"Further, the Commission will be accepting further comment from previous participants in the MDWG regarding cost allocation for implementation of a seamless move mechanism within each EDU footprint," PUCO said

PUCO denied a series of other proposed retail market enhancements.

PUCO denied adoption of instant connect, which in Ohio allows a new customer to begin receiving generation service from a CRES immediately upon starting new service, instead of the customer having to initially take default service under the SSO for the first month.

"Upon review of the comments and the Staff Report, the Commission finds that instant connect should not be adopted at this time. Instant connect was primarily discussed within the context of mercantile customers, and the Commission agrees with Staff's conclusion that in balancing the costs associated with implementation of instant connect against the overall benefit, that instant connect should not be adopted at this time. Further, instant connect is a more over-arching retail enhancement that has broader implications than just the scenario whereby a customer is moving to a new address within the same service territory," PUCO said

However, the Commission said that it is "troubled" by the scenario raised by suppliers whereby a name change of a business could result in that business being sent back to default service.

"This is hardly business friendly, and the Commission must be cognizant of practices in the State that act as a hindrance to economic development. These types of ministerial changes should not result in a mercantile customer being sent back to default service. The EDUs and suppliers are encouraged to work through this issue, and if they cannot, then the issue should be addressed in the rules proceeding that has been opened at the Commission [Case No. 17-1842-EL-ORD]," PUCO said

PUCO specifically ordered that, "stakeholders work to ensure that ministerial changes to the profile of a mercantile customer not result in that customer being dropped from its CRES provider and sent back to default service."

PUCO also denied implementing contract portability. In Ohio, contract portability is the transfer of an existing CRES contract to a new address, with neither the customer nor the CRES provider having an opportunity to reject the contract move. The customer may revert back to default service for the first month of service before resuming generation service from the CRES provider.

"The Commission finds that contract portability should not be adopted. First, per the Staff Report, there was not full support for the methodology by suppliers in the MDWG. Second, per the Staff Report, the methodology would be difficult to implement due to the fact that no existing contracts currently allow portability. (Staff Report at 5-7.) Thus, allowing this function would require all existing contracts to be modified, which would incur considerable cost for the CRES providers and may unnecessarily interfere with their contracting rights with their customers. Finally, because the contract automatically ports to the customer's new address, we may be inadvertently restricting customers from researching and ultimately choosing potentially more advantageous rates available for their new home or business location, in addition to other opportunities, such as aggregation programs or smart meter programs," PUCO said

PUCO also denied adopting a "warm transfer" process, which allows a customer to transfer an existing CRES contract to a new address, through a three-way conference call with the electric distribution utility (EDU) and his or her CRES provider. Under such proposal, the customer would be advised of all choice options and then must consent to the transfer. The customer would revert back to default service for the first month before resuming generation service from the CRES provider.

"The Commission finds that warm transfer should not be adopted. The warm transfer process was not discussed in as much detail as the other processes during MDWG discussions and has its own difficulty in implementation as explained by the EDUs and specifically by AEP through its trunk looping discussion. Further, warm transfer garnered little support within the MDWG. Suppliers and consumer groups panned the approach, and the EDUs were not overwhelmingly supportive either. Additionally, warm transfer requires substantial time and effort for the customer, thereby creating disincentive for the customer to continue shopping, a concept that is antithetical to the very reason that the COI Case was initiated," PUCO said

Case No. 12-3151-EL-COI

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