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PUC Staff Recommend Retail Suppliers Be Responsible For 100% Of Costs Of Seamless Move Implementation

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
Reporting by Paul Ring •

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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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