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Utility To Study Providing Retail Suppliers With Lists Of Customers Paying Highest Retail Supplier Rates

Rate Case Settlement Addresses Billing Enhancements, Other Retail Market Issues


January 7, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The following story is brought free of charge to readers by EC Infosystems, the exclusive EDI provider of EnergyChoiceMatters.com

A rate case settlement at Vectren Energy Delivery of Ohio, Inc. would include a provision requiring the study of the feasibility of providing to retail suppliers lists of customers who pay the highest rates to their retail supplier

Under the Stipulation, Vectren agrees to review the feasibility (including the availability of company IT resources and compliance with regulatory requirements), cost, including cost-effectiveness, and prudence of including in customer lists, or otherwise providing Choice Suppliers, as defined in Vectren’s tariff, a list of choice customers whose current commodity rates are in the top twenty-five (25) percent of all Choice customer rates.

Vectren agrees to conduct this review within 90 days of the approval of the Stipulation and to share and discuss Vectren’s review with Signatory Parties and other interested parties. Actual customer rates will not be included in the lists.

Customers that opt-out of inclusion in the customer lists available to Choice Suppliers pursuant to Vectren’s tariff will be excluded from any lists that may ultimately be provided in accordance with this provision.

To the extent determined feasible, cost-effective, and prudent, Vectren will review the estimated cost and work required to make the lists available to Choice Suppliers and will provide that information to Signatory Parties and other interested parties. Costs associated with this provision shall be recovered through the customer list fee, and to the extent such fees do not cover the incremental costs associated with the provision of the top twenty five percent list, Vectren has no obligation to implement this provision unless the requesting Choice Supplier pays for any incremental costs. To the extent that the top twenty-five percent list is not includable in the customer list, Vectren has no obligation to implement such provision unless the requesting Choice Suppliers pay for any incremental costs.

The settlement also includes various provisions related to the retail market as described below:

Mandatory Assignment of Pipeline Capacity: Some capacity contracts up to 5,000 Dths/day may be released only to SCO Suppliers.

Facilitating customer communication with their SCO Supplier: Vectren agrees to continue its coordination with Standard Choice Offer (SCO) Suppliers and customers served under the SCO. To this end, Vectren agrees that its call center will transfer a call from an SCO customer to its SCO Supplier, or identify the relevant SCO Supplier contact information for the SCO customer, when in Vectren’s reasonable discretion Vectren determines that the SCO customer has specific questions with respect to or in relation to the SCO and that it is reasonable under the circumstances of the call to either transfer the call or direct the SCO customer to the applicable SCO Supplier. PUCO Staff shall inquire whether SCO suppliers are currently sending welcome letters to customers as required. Staff shall provide the results of its inquiry to signatory parties.

Exit the Merchant Function Discussion: Vectren agrees to meet periodically with interested parties to discuss in good faith an exit of the merchant function. Vectren agrees to participate in the first of these interested party meetings within 120 days of the approval of the Stipulation and at least three times annually thereafter until the earlier of the filing of an application to exit the merchant function or the filing of Vectren’s next rate case. Notwithstanding any provision of the Stipulation to the contrary, Vectren agrees to participate in these meetings with interested parties regardless of the outcome of the Commission’s review of the Stipulation.

Billing Enhancements: Vectren agrees to meet periodically with interested parties and to discuss in good faith billing enhancements for which implementation and/or resolution will support the policies enumerated in R.C. 4929.02. Vectren agrees to participate in the first of these interested party meetings within 120 days of the approval of the Stipulation and at least three times annually thereafter until the filing of Vectren’s next rate case. Discussions will include, but are not limited to: billing system upgrades (e.g., fixed bill through a rate-ready code, additional rate-ready billing codes, bill-ready billing, billing a rate based on NYMEX prices, plus or minus a value, permitting pre-payment of the commodity portion of the bill, and allowing a "zero price" rate-ready code), and access to more granular individual customer information (e.g., peak day information, customers’ with highest rates, plant protection level, Maximum Daily Requirement, etc.). Notwithstanding any provision of the Stipulation to the contrary, Vectren agrees to participate in these interested party meetings regardless of the outcome of the Commission’s review of the Stipulation.

Vectren also agrees to review the feasibility (including availability of Company IT resources), cost, including cost-effectiveness, and prudence of upgrading its current billing system to allow the submission by Choice Suppliers of a rate code with a zero charge for the commodity of natural gas to enable each Choice Supplier to submit a dual bill for a portion of the customers in its pool, while utilizing rate-ready billing for the remainder of the customers in its pool. Vectren agrees to share and discuss this review at the first customer choice and billing improvements issues interested party meeting. Vectren also agrees to review and share the feasibility, cost, and prudence of including this functionality in a successor billing system once such successor system is known or being developed.

Dual Billing: Vectren has dropped its proposal that would have required that dual bills be, "consistent with Company’s bill format and billing information," and that would have subjected a supplier's dual bill format to Vectren's approval prior to the issuance of any bill to customer.

Customer Peak Day Information: Vectren agrees to review the feasibility (including availability of Company IT resources, and compliance with regulatory requirements), cost, including cost-effectiveness, and prudence of providing Pool Operators with peak day information for Rate 345 and Rate 360 customers under the Company’s current and subsequent IT infrastructure as part of an electronic file, or similar approach. Within 120 days of approval of the Stipulation Vectren agrees to share and to discuss the results of its review with Signatory Parties and other interested stakeholders. If Vectren determines that such data sharing is feasible, cost-effective, and prudent, Vectren agrees to use good faith efforts to implement such a change. The sharing of such customer peak day information is also contingent on Pool Operator having or obtaining customer consent for the release of the information.

Customer Choice and Billing Upgrades in ETC Rider: The Signatory Parties acknowledge that cost recovery under the ETC Rider can include billing system upgrades described above or identified pursuant to the sections titled Customer Peak Day Information and Billing Enhancements. If an identified improvement and upgrade under those sections is determined to be feasible, cost-effective, and prudent by Vectren, Vectren shall use good faith efforts to implement the improvement before the next base distribution rate case. Operation and maintenance expenses and capital investments recoverable under the ETC Rider for such improvements are subject to an audit and an aggregate cap not to exceed $850,000. The return associated with the capital investment is not subject to the $850,000 cap. To the extent that implementation of any such improvement and upgrade would exceed the $850,000 cap, Vectren may but has no obligation to implement any such improvement or upgrade. In the event Vectren elects not to implement any improvement or upgrade as a result of the cap, it will meet with interested Signatory Parties to discuss its rationale and to discuss options for cost recovery which such options may include, but are not limited to, Vectren filing an application seeking approval for cost recovery for amounts that exceed the $850,000 cap

Other tariff changes:

City-Gate Allocation Non-Compliance Charge: The stipulation modifies an earlier proposal regarding Vectren proposed language regarding System Beneficial Deliveries and the City-Gate Allocation Non-Compliance Charge. Under the revised language, Vectren may initially "request" (rather than require) Pool Operator(s) to voluntarily: 1) vary its daily delivery from the nominated delivery quantities; 2) deliver to a different pipeline and/or city-gate; and/or 3) make other changes to gas deliveries to ensure system integrity or mitigate the risk of pipeline penalties being assessed. If voluntary delivery changes are not adequate to rectify the situation, Vectren shall change its city-gate allocation delivery requirements applicable to all Pool Operators. Failure to comply will result in Pool Operators being assessed the City-Gate Allocation Non-Compliance Charge. Requirements under this provision are distinct from OFO requirements. In the absence of exceptional circumstances, Vectren shall provide least 24 hours advance notice to Pool Operators for a change in City Gate Allocations

Utility Consolidated Billing/Dual Billing Election: Under the stipulation, suppliers may change the billing option for their pool customers (dual vs. UCB, which is applicable to all of the supplier's pool customers) by providing no less than 6 months prior written notice to Vectren, and cannot change it more frequently than once in any six month period. This reflects a modification of Vectren's original proposal which would have permitted a billing option change only once during every 36-month period, with notice of three months required for such change.

The settlement was agreed to by Vectren Energy Delivery of Ohio, Inc. (VEDO or the Company), the Staff of the Public Utilities Commission of Ohio (Staff), the City of Dayton (Dayton), Federal Executive Agencies (FEA), Interstate Gas Supply, Inc. (IGS), and the Retail Energy Supply Association (RESA)

Case 18-0049-GA-ALT et al.

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