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Ohio Utility Says Any Project To Assess Requirements To Implement Supplier Consolidated Billing Could Not Begin Until Late 2023

Utility Seeks Recovery Of Costs For New Customer Care System

Utility's Infrastructure Modernization Plan Includes Rebate For EV Customers To Participate In Utility Load Management

Plan Notes Potential For Later Request To Own EV Charging Stations

Plan Includes Smart City Infrastructure

September 25, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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Duke Energy Ohio has sought approval at the Public Utility Commission of Ohio for cost recovery of an infrastructure modernization plan which includes a new customer care (CIS) system, with Duke stating that any project to assess the requirements to implement supplier consolidated billing could not begin until late 2023

As previously reported by, PUCO in December 2018 said that Duke's forthcoming CIS plan should "accommodate" supplier consolidated billing

PUCO had ordered in December 2018 that, "[T]he Commission is persuaded that there are benefits associated with supplier consolidated billing and Duke's CIS plan should accommodate that service. Finally, as the Company's CIS plan is to be filed in a separate proceeding and be subject to a hearing, we determine that is the proper forum in which to explore these issues fully."

In response to PUCO's directive, a witness for Duke Energy Ohio stated, as part of the infrastructure modernization plan filing, that, "The Commission's Opinion and Order states that the Commission is persuaded that there are benefits associated with supplier consolidated billing but that this application was the proper forum to explore these issues fully. Duke Energy Ohio believes there are a number of details to be considered before implementing supplier consolidated billing. For example, Duke Energy Ohio is a combination gas and electric utility. Today, its customers receive a single bill for all gas and electric services. Many of the Company's customers have different suppliers for their electric and natural gas commodities, with Duke Energy Ohio being the only common thread. The Company must know how the Commission desires these customers to be treated. Will one supplier now be responsible for billing another supplier's rates? Will customers be forced to receive separate gas and electric bills going forward? Who will bear the costs of customer education and the additional call center volume that will occur during this transition away from the utility consolidated billing that has been in place for decades. These are all items that will need to be addressed."

Duke's witness further said that, "Since this is an Ohio specific issue, all costs to implement this should be borne solely by Ohio suppliers who desire this functionality. Suppliers will need to have the customer call centers and processes in place to be responsive to all types of customers inquiries such as work orders and service outages that will likely come to them if the customer's monthly bill is no longer sent by Duke Energy Ohio. Although Duke Energy Ohio is still the distribution service company for both gas and electric service, it is not clear that customers will understand this dichotomy of services."

Duke's witness further said that, "Additionally ... the Company is deploying new capabilities with Customer Connect [the new CIS] to enhance the customer experience, including a new, more customer-friendly bill to help customers more easily view and understand their bill and energy usage, and customers who participate in supplier consolidated billing would not receive the benefits of the program and new bill format."

See background on Duke's new bill here

Duke's witness further said that, "Furthermore, the requirements to support supplier consolidated billing are unknown, and the Company believes a project would be needed to assess the level of effort and cost to implement this functionality in Customer Connect. The design and build of Customer Connect is nearly complete and testing of the solution will begin in early 2020; therefore, any project to assess the requirements to implement supplier consolidated billing could not begin until late 2023, after the deployment and stabilization of Customer Connect."

With regard to seamless moves, Duke said that the Company completed the design of the Customer Connect Program in June 2019, and has incorporated a seamless move function. The specific design of seamless move is based on requirements used in other states, absent any specific requirements from the Commission, and will be detailed in the operational plan to be filed by Dec. 31, 2019. Additionally, Duke will meet with CRES providers to ensure alignment on the details and protocols, a witness for Duke said

The seamless move capability will be available in the fall 2022 when the core meter-to-cash solution is implemented for Duke Energy Ohio, "provided the Company's operational plan is approved with minimal exception," a witness for Duke said

"Furthermore, any exceptions, or changes, must be identified by the end of first quarter 2020 (March 31, 2020) to be included with the implementation of Customer Connect," a witness for Duke said

Duke expects the new CIS to be fully deployed in fall 2022

Duke said that a new CIS is needed, among other reasons, because the existing CIS is a premises-based system, "and not designed to efficiently support new capabilities, including personalized experiences for customers, advanced pricing structures, and tools for customers to better manage their energy consumption."

The new CIS will support more innovative rate designs, Duke said

"With the Company's existing CIS, many new rates are very time consuming and burdensome to implement due to the antiquated architecture of the system and the complexity of coding and testing the rates. In contrast, in the modern CIS, new rates will be configurable and much simpler to implement, improving the Company's responsiveness to regulatory or market changes. Also, many modem rate structures (e.g. net metering, time-of-use, etc.) are pre-built into the system because the software is leveraged in European and other markets, where the use of these more modem rate structures is far more advanced," a witness for Duke said

The new CIS will also have integrated analytics. "The integrated analytics capabilities of the new platform will then leverage this customer profile data to personalize experiences and better serve customers through every channel. For example, the new platform will predict the intent of customers when they call Duke Energy, thereby improving their experience in the IVR and routing them to the customer care specialist best suited to meet their needs. This same capability will be leveraged to prioritize what information is conveyed to the customer and convey that information in the medium preferred by the customer, whether it is via web, email or other channels, to ensure it is timely, relevant and valuables to him or her. These are just two examples of the multiple opportunities to leverage real-time analytics to improve our customers everyday experience with Duke Energy," a witness for Duke said

Duke's application also seeks approval for various EV programs. The programs are largely confined to rebated and make ready investments, and would not include utility ownership and operation of EV charging stations. However, there are two notable points

First, under a residential rebate EV pilot program, a residential customer would receive up to $500 for participating in monthly utility-managed load management events. The pilot would include 1,000 customers

"Usage will be billed under the customer's existing residential rate. The Company will collect usage characteristics of EV charging behavior, better understand potential grid and utility impacts from EV charging, and implement utility-managed charging," a separate witness for Duke said

Second, Duke proposes to review the proliferation of DC Fast Charging (DCFC) chargers under its program providing "make ready" investments. If third parties have not fully subscribed to the "make ready" investments for DCFC installation, Duke said that it could in the future request from PUCO authorization to own and operate up to 25 DCFC chargers

Duke also sought approval to implement smart streetlight infrastructure that could support various "smart cities" offerings such as Security/Safety Cameras; Pedestrian counters; Traffic control devices; Environmental sensors (air quality, temperature, hazardous gases, etc.); Waste management sensors; Gunshot detection sensors; Parking space monitoring; Digital banners; Wi-Fi networks; Small cell wireless.

Case 19-1750-EL-UNC et al.

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