Utility Files To Recover Costs Of Implementing Seamless Moves From Retail Suppliers

December 17, 2019

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

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Ohio Power (AEP Ohio) has filed a seamless move implementation plan at the Public Utilities Commission of Ohio which includes recovering implementation costs from retail electric suppliers

AEP Ohio estimates that programming its systems to implement seamless moves, as well as ongoing maintenance of these systems, generating and mailing of additional rescission letters, and AEP customer call center representatives’ time in educating eligible customers about seamless moves will cost approximately $2.4 M in capital, and may have some on-going annual O&M.

AEP Ohio estimates that based on the most recent 12 month period approximately 32,350 residential customers would have been able to participate in a seamless move if this feature had been available.

"AEP Ohio plans to recover this cost from all customers that are eligible to take advantage of this service, therefore the approximate cost per eligible seamless move transaction is $24.02," AEP Ohio said

"This amount will be charged to the CRES [retail] providers with which eligible customers are under contract through the monthly invoice AEP Ohio currently sends each CRES provider actively serving customers in the Company’s service territory. This costs will be trued-up and recalculated annually," AEP Ohio said

To the extent the seamless move program is discontinued prior to recovery of the full implementation costs, AEP Ohio requested recovery of any remaining costs plus carrying charges through the Power Forward Rider.

In contrast to charging retail suppliers for seamless move implementation costs, the FirstEnergy Ohio utilities proposed recovery though a nonbypassable rider (discussed further below)

Turning to other elements of AEP Ohio's seamless move implementation plan, AEP Ohio said the following concerning a CRES provider's choice to discontinue service: "If the CRES provider decides it no longer wants to serve the customer under the contract terms and conditions, the CRES provider can send an EDI 814D transaction and the normal drop process will occur on AEP’s system. In other words, if the drop is received more than 12 days prior to the next meter read date the drop transaction will be processed as of the next meter read date. If received less than 12 days before the next meter reading date, the drop will occur at the next eligible meter reading date. As discussed in the recent PUCO Staff Seamless Moves working group discussions, the CRES provider is assumed to grant consent for the seamless move and has the ability to decline the seamless move by dropping the customer through the normal process."

Concerning customer billing, AEP Ohio said, "If AEP is providing consolidated rate ready billing on behalf of the CRES provider, it will bill both locations at the current contract rate during the overlap period. Any other type of billing (dual billing, consolidated bill ready billing, supplier consolidated billing) will be assumed to be at the same contract rate, although AEP Ohio will not have systems in place to verify any pricing other than utility consolidated rate ready billing."

Concerning PJM Settlements, AEP Ohio said, "When a CRES provider serves a retail customer, the amount of electricity supplied by the CRES provider and the amount of electricity consumed by the customer is trued-up or 'settled' within PJM. AEP Ohio will settle both the old and the new service locations with the CRES provider. If the customer rescinds the seamless move, and therefore electricity consumed at the new location is not taken under contract with the CRES provider, it will assumed to be taken under AEP Ohio’s SSO service. However, if the rescission is provided after service starts at the new location, AEP Ohio will assign the energy consumed to SSO service after the fact, capacity charges could be the responsibility of the supplier since it is settled monthly with no true up mechanism. The suppliers have agreed to this mechanism since the only customers under this program are residential customers."

Citing a PUCO Staff workgroup report, AEP Ohio said that seamless moves shall only apply to residential customers

AEP Ohio estimates that it will take 18 months to program and fully implement seamless moves.

FirstEnergy Ohio EDCs

Ohio Edison Company, Cleveland Electric Illuminating, and Toledo Edison filed a seamless move implementation plan under which the EDCs proposed that all costs associated with the seamless move Operational Plan shall be fully recovered through the companies’ nonbypassable Government Directives Recovery Rider (Rider GDR).

Concerning a supplier seeking to reject a seamless move, the FirstEnergy EDCs said, "Once the customer confirms, the Company will submit an Electronic Data Interchange ('EDI') 814 Move transaction that same day to notify the CRES provider of a pending seamless move. As discussed in the stakeholder meeting on September 26, 2019, consent of the CRES providers is implied. The 814 Move transaction would mimic the 814 Move used as part of the seamless move process in Pennsylvania, pending approval by the Ohio EDI Working Group ('OEWG'). The primary functions of the 814 Move transaction are to notify a CRES provider of a pending seamless move, provide relevant information regarding the move, and initiate the enrollment process for the new service location."

Concerning NSPL and similar values for seamless move customers, the FirstEnergy EDCs said, "To effectively price transmission service and generation capacity obligations, each premise has an assigned network service peak load ('NSPL') for transmission capacity and a peak load contribution ('PLC') for generation capacity. The PLC and NSPL are premise-specific, which means customers do not transfer the NSPL and PLC capacity obligations from their current premise to a new premise. Instead, the Companies must assign new NSPL and PLC capacity obligations at the new premise, which are calculated as the class average default value until new values are assigned annually on January 1st for NSPL and June 1st for PLC (based upon historical usage at the new premise)."

"When a seamless move is processed at a new premise, the customer’s NSPL and PLC values may be different than the values that were assigned at the old premise. The 814 Move for the new premise will include updated NSPL and PLC values so that CRES providers know the new values," the FirstEnergy EDCs said

For a seamless move at the FirstEnergy EDCs, the customer must have an active residential account with the company

Further concerning customer eligibility for seamless moves, the FirstEnergy EDCs said that the new location must be an active premise, which is a necessary prerequisite for the Company to assign the seamless move customer an account number on a pending active basis. A 'pending active' basis means an account number is set to become active at a specified future date.

Concerning supplier pricing requirements, the FirstEnergy EDCs said, "In order to enable the Companies to effectuate a seamless move, CRES providers will be required to maintain the same pricing, billing option, and tax exemption status at both the current premise, as well as the new premise, until the seamless move is completed. This requirement helps ensure that the Companies will not inadvertently take action that would trigger the requirements of Ohio Administrative Code Section 4901:1-10- 33(E)(5)."

The FirstEnergy EDCs intend to implement the seamless move plan 12 months after the final order in the proceeding

Cases 19-2141-EL-EDI, 19-2150-EL-UNC

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