Utility Seeks To List Amount Of Shadow-Billed Default Service Cost On Shopping Customers' Bill, Prominently On First Page

Utility Says Residential Shopping Customers, "Are Pervasively Overpaying," Versus Default Service

Utility "Encourage[s]" PUC To Make Retail Supplier Pricing More Transparent Through Regulatory Requirements Imposed On Retail Suppliers

August 25, 2020

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Reporting by Paul Ring • ring@energychoicematters.com

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Ohio Power Company (the 'Company' or 'AEP Ohio') filed an application at the Public Utilities Commission of Ohio for approval of a modified bill format that would provide the shadow-billed total supply cost that a shopping customer would have paid, had the customer been on the Standard Service Offer, on the first page on a utility consolidated bill for residential customers

AEP Ohio said, "The proposed change is to add a top-level customer message on the first page of the bill that includes the current SSO rate known as the price-to-compare (PTC)."

Specifically, the language would state, "The supply portion of your bill using AEP Ohio's Standard Service Offer rate (also known as the Price-to-Compare) of $0.0xx per kWh would have been $xx.xx. Compare with your current supplier charges listed below on this bill for potential savings."

The information would appear near the top right of a customer's bill, under the heading "Notes from AEP Ohio". See a sample bill with the change here (page 4).

"This higher profile message will help ensure that residential customers see and understand their options for shopping or not shopping. This is consistent with the Commission’s efforts to help inform and educate residential customers regarding their choice rights (to either shop or take SSO service). The existing PTC message under the continued 'Notes from AEP Ohio' section will remain unchanged as that message also includes a reference to the Commission’s Apples-to-Apples website and an additional instruction on how to use the PTC," AEP Ohio said

"Frankly, the Company would like to do more to help inform customers about their shopping rights and educate them on how to make the best decision for them given the opportunities available. Based on information the Company has, it appears that residential customers are pervasively overpaying (as compared to the SSO) when shopping for generation service. For that reason, the Company endeavors to help its residential customers (and small commercial customers) get a better value for electricity," AEP Ohio said

"While we studied the potential to do a customer-specific comparison on each bill that would show how much they are saving or over-paying with their CRES supplier, it is not possible to determine in all cases what the supplier’s effective kWh charge is for commodity services in order to make an 'apples-to-apples' comparison with the PTC. Some suppliers have fixed monthly charges, some have non-commodity fees and other service charges. With bill ready consolidated billing, AEP Ohio does not have the ability to translate the billing data to a per kWh commodity rate that would be useful to customers in looking at the PTC. Even with rate ready consolidated billing, the Company does not have clear visibility into the effective kWh commodity rate due to fixed charges and non-commodity charges. Obviously, if the Company as the billing agent cannot figure out what the effective kWh rate is for a customer, it is probably also the case that customers frequently cannot readily determine that same information. Regardless, until such time that the Commission clarifies such matters through regulatory requirements imposed on CRES providers (which AEP Ohio would encourage), the Company lacks the ability to provide additional help to residential customers in this regard. In any case, the Company for now is proposing a simple message that indicates what we do know: what the supply charges would be under the current SSO rate," AEP Ohio said

In accordance with 4901:1-10-33(F), Ohio Administrative Code, the new format will be automatically approved absent Commission ruling and the Company plans to implement the new format effective with the first billing cycle in November of 2020.

Case 20-1408-EL-UNC

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