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Consumer Counsel Says Default Service Shadow Billing, Listing Price To Compare On Bills Would Be Better Use Of Ratepayer Dollars Than Retail Market Billing Enhancements

Consumer Counsel Says Proposal Which Could See Retail Supplier Provided With List Of Customers Paying Highest Rates May Be Discriminatory

April 3, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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The Office of the Ohio Consumers’ Counsel has opposed several provisions related to retail market enhancements contained in a contested rate case settlement at Vectren Energy Delivery of Ohio

As exclusively first reported by in January, a settlement among Vectren, PUCO Staff, and retail suppliers in Vectren's rate case would, among other things require Vectren to review the feasibility and cost providing Choice Suppliers with a list of choice customers whose current commodity rates are in the top twenty-five (25) percent of all Choice customer rates.

Vectren also agreed to review and discuss various retail market billing enhancements, including 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). Settling parties agree that such costs, subject to a cap, could be recovered via the nonbypassable ETC Rider

See a full discussion of the various retail market enhancements in our prior story here

OCC said that, "using the ETC Rider to collect costs from customers for billing enhancements that benefit IGS and RESA is patently unfair, especially when such funds could and should be used to assist customers in better understanding their savings or losses when they participate in Vectren’s choice program."

"For example, Vectren does not currently track the difference between what a customer pays a supplier and what that customer would pay for natural gas supply under a standard offer from Vectren. According to [OCC witness] Mr. Williams, this practice, known as 'shadow billing,' would educate and assist the customer in making an informed choice regarding natural gas supply service," OCC said

"The PUCO’s Energy Choice website itself demonstrates the need for more customer information on this front. Specifically, the website indicates that Vectren’s current SCO rate is $0.47669 per ccf. But in the PUCO’s 'Apples to Apples' comparison, there are 38 marketer offers, of which only five are lower than Vectren’s SCO. Furthermore, two of those five offers are introductory offers where the rate is only good for two months," OCC said

"Because the majority of marketer offers exceed Vectren’s SCO rate, customers would greatly benefit from a 'price to compare' message in their bills. Implementing billing enhancements to inform and educate customers in this manner (as opposed to making customers pay for billing system upgrades for the primary benefit of marketers and suppliers) would be a much more reasonable use of ETC Rider funds," OCC said

OCC also said that the proposal which could lead to retail supplier receiving lists of customers paying the highest commodity rates could be discriminatory

"The Settlement’s marketer and supplier provisions also require Vectren to review the feasibility of providing suppliers with a list of Choice customers whose commodity rates are in the top 25% of all Choice customer rates. This requirement is contrary to the public interest and established regulatory principles as well. Specifically, Ohio Revised Code 4929.22(F) requires the PUCO to establish rules, as a part of a gas company’s minimum service requirements, that require that 'a natural gas company make generic load information available to a retail natural gas supplier . . . on a comparable and nondiscriminatory basis, unless, as to customer information, the customer objects.' But sharing customer information to suppliers in the form of a 'top 25%' list could be discriminatory, and that information could be used by suppliers to market additional products and services to customers on that list," OCC said

"In addition, the policies set forth in Ohio Revised Code 4929.02(A) include promoting the availability of adequate, reliable and reasonably priced services. And in establishing reasonably priced services, the SCO should be considered the benchmark rate, not the rates paid by those customers who pay the highest supplier rates. Axiomatically, even if the 'top 25%' customers switch suppliers or end up paying a lower rate, those rates may still be too high when compared to the SCO rate. Mr. Williams testified that this is yet another reason why customer bills should include the SCO rate as the 'price to compare' and why any billing system upgrades funded through the ETC Rider should incorporate technology to facilitate 'shadow billing' reporting by Vectren," OCC said

In a brief, Vectren noted that the stipulation does not require the provision of the top 25% list, only a review of the feasibility of such list

"Any such review of the 'feasibility' of providing choice suppliers with this top 25 percent list, including whether providing the information complies 'with regulatory requirements,' would have included a review of OCC’s concern, namely whether the sharing of this information would violate the statutory provisions cited by OCC witness Williams," Vectren said

Case No. 18-0049-GA-ALT

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