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PUC Staff Recommend Retail Suppliers Be Responsible For 100% Of Costs Of Seamless Move Implementation
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In comments on the seamless move implementation plans of the four investor-owned electric distribution companies, Staff of the Public Utilities Commission of Ohio proposed that retail suppliers be responsible for 100% of the costs of seamless moves
Staff did not propose a specific mechanism to allocate any costs among individual retail suppliers
See background on the EDCs' seamless move plans in our prior stories below
• Duke, DP&L
• AEP Ohio, FirstEnergy EDCs
As noted in our prior stories, several utilities proposed to recover costs of seamless move implementation in distribution rates or a nonbypassable charge
In commenting on the FirstEnergy EDCs' plans, Staff said, "Staff believes that CRES
suppliers should be responsible for one hundred percent of the expense of the seamless
move function." Staff made similar recommendations in comments on the other EDCs' plans
Staff noted that Duke Energy Ohio’s seamless move plan proposes to transfer all customers who are a part of
Governmental Aggregation to the supplier that was serving the Governmental Aggregation; however, according to Duke’s plan, the customer will no longer be included in the
Governmental Aggregation at the new premise.
Staff said that, "Staff believes customers who participate in
aggregation, governmental or otherwise, should not be eligible for seamless move as
proposed by Duke."
However, Staff said that if Governmental Aggregation customers are allowed to participate in
seamless moves, "the customer must remain within the Governmental Aggregation program
that the customer is currently a part of, and continue to have the Governmental Aggregation
indicator in Duke’s CIS system."
Staff did recommend that customers be informed about governmental aggregation as a supply option during the discussion with the utility CSR concerning a move
"Staff believes that customer education regarding
choice should occur at the time a transfer is requested. To that end, Staff recommends that
Duke educate customers regarding the choices in energy suppliers, including governmental
aggregation, shopping, and default service," Staff said. Staff made similar comments concerning the other EDCs' compliance plans
Concerning Dayton Power & Light's plan, which as previously reported would not allow retail suppliers to reject a seamless move requested by a customer, "Staff recommends DP&L allow CRES suppliers to drop seamless move
customers."
In comments to PUCO, the Ohio Consumers' Counsel opposed work on seamless moves as a costly non-essential service during the COVID-19 pandemic.
"The PUCO’s seamless move mechanism is an unnecessary (non-essential) and costly
addition to utility service that benefits too few customers at too great a cost. OCC recommends
that work on and charges for 'non-essential' utility services such as the seamless move
mechanism should be suspended until after the emergency ends (or the PUCO determines
otherwise based on a review and analysis of information available at that time). But if the PUCO
decides to proceed with its seamless move mechanism implementation (which it should not), it
should require that all seamless move costs be borne by those who primarily benefit–the energy
marketers," OCC said
"Non-essential seamless move activities should be
suspended to protect consumers from paying additional (and possibly significant) charges related
to these non-essential activities until some future time when the PUCO determines the activities
are warranted," OCC said
The Northeast Ohio Public Energy Council said that government aggregation customers should be included in seamless move eligibility
In comments on the FirstEnergy EDCs' plan, NOPEC said, "As proposed in the
FirstEnergy Plan, NOPEC’s government aggregation customers are required to pay the cost of
the seamless moves requested by CRES suppliers, without receiving the benefit of seamless
move. NOPEC’s customers would not receive this benefit because the FirstEnergy Plan, unlike
Duke’s plan, does not allow governmental aggregation customers to participate[.]"
In comments on the FirstEnergy EDCs' plan, NOPEC said, "By charging the seamless move costs to all EDU distribution customers instead
of to the CRES provider requesting the seamless move, the FirstEnergy Plan
recovers generation-related costs through distribution rates, in violation of R.C.
4928.02(H)[.]"
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PUC Staff Recommend That Muni Aggregation Customers Not Be Eligible For Seamless Moves
Consumer Advocate Seeks To Shelve Work On Seamless Moves, Calling Mechanism A Costly "Non-Essential" Service During COVID Pandemic
May 4, 2020
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Copyright 2010-20 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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