Updated: Utility To Revise Price To Compare, "Savings" Advisory Language On Bills

August 28, 2019

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

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Update, 9/16:

Duke Energy has clarified that Price To Compare language will appear on all bills, both for SSO customers and utility consolidated bills for customers on CRES service, per the Ohio Administrative Code. A representative for Duke said that the omission of the Price to Compare language from the utility consolidated bill examples filed with PUCO was an oversight

Original story:

Duke Energy Ohio has filed at the Public Utilities Commission of Ohio to revise its bill format, for electric and gas service

Notable is an apparent language change concerning electricity Price to Compare information listed on customer bills

Sample bills under the revised format filed by Duke include the language, "Price to compare: If you’re considering using a different electric supplier, their rate would have to be lower than [listed rate] per kWh for you to save money. Visit www.energychoice.ohio.gov to compare rates of all electric suppliers or contact Duke Energy for a written explanation."

Based on the sample bills filed by Duke, this Price to Compare language would only appear on the bills of customers served under electricity default service. The Price to Compare language does not appear on sample utility consolidated bills for customers receiving service from a retail electric supplier [see clarification update above].

While nothing in the language may be factually inaccurate, it is notable that there is no duration or date listed for the Price to Compare, which may change quarterly (though quarterly variations, due to riders such as AER and/or reconciliation, may be de minimis). Moreover, while it is not incorrect that the supplier rate would have to be lower than the Price to Compare in the instant billing period for the customer to save money in such billing period, the statement may give an incomplete picture to the customer given that the customer may "save money" over the life of a retail contract despite, in some instances, the Price To Compare being lower than the retail supplier rate in a given month, due to variability in the Price to Compare, versus, for example, a fixed supplier rate. This issue could easily be addressed by adding the phrase "for this billing period" in Duke's sample Price to Compare language (prior Price to Compare language, noted below, while not explicitly limiting the savings statement to a specific billing period, did note that the comparison was for the, "usage that appears on this bill," implying that the instant savings statement may not be applicable to other usage amounts and bills).

See samples of the new Duke bills here

For comparison, a sample bill filed by Duke when updating its bill in 2015, to reflect the addition of retail supplier logos, included different Price to Compare language. Such 2015 sample utility consolidated bill (example here) had stated, "PRICE TO COMPARE: In order for you to save money, an electric supplier must offer you a price lower than 6.33 cents per kWh for the same usage that appears on this bill. To review competitive offers from electric suppliers, visit the Public Utilities Commission of Ohio's "Energy Choice Ohio" website at http://energychoice.ohio.gov. To learn more about Price to Compare, visit www.duke-energy.com or contact Duke Energy for a written explanation."

It is believed that this 2015 sample bill reflects the most recent bill format used by Duke, except for the subsequent addition of a note concerning the amount of certain riders (energy efficiency, peak demand reduction, renewable energy). Note that, unlike the new sample bills, the 2015 sample utility consolidated bill included the Price to Compare language even though the sample customer was taking supply from a competitive retail supplier. However, a sample Ohio utility consolidated bill on Duke's website does not include the Price to Compare language on the sample bill for a customer taking competitive supply, though such sample on the website may not be reflective of the latest approved billing format changes

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