PUC Approves Settlement Concerning Dayton Power & Light Advanced Meter Roll-Out Which Addresses Default Service Issues
Stipulation Includes $1 Million Payment (Shareholder-Funded) To Solar Affiliate Of Retail Supplier To Support Solar Development
Smart Grid Roll-Out Contemplates Execution Of Third Party Apps, From Utility & Third Parties, By AMI Meters
Addresses Supplier Access to AMI Data, Use In Wholesale Settlement
Commissioner "Strongly Support[s]" Required TOU Option For Default Service Customers, Concerned With Potential Sunset
June 15, 2021 Email This Story Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • email@example.com
The following story is brought free of charge to readers byEC Infosystems, the exclusive EDI provider of EnergyChoiceMatters.com
The Public Utilities Commission of Ohio approved, without modification, a stipulation among Dayton Power & Light Company (DP&L), PUCO Staff, Industrial Energy Users-Ohio and several other large customer groups, IGS Energy, and several environmental groups which authorizes deployment of advanced meters, an upgraded customer information system, and other grid modernization activities (Smart Grid Plan Phase I or SGP I)
Notably, the adopted stipulation addresses DP&L's current default service plan (its prior reversion to electric security plan I, or ESP I) and elements of a future default service plan (ESP IV). See background on the reversion to ESP I here
During the 2020-2023 period, the stipulation's signatory parties agree
not to challenge or otherwise advocate against DP&L's right to
operate under its currently implemented ESP I and not to challenge
or otherwise advocate against any provision of its current ESP I
before the Commission, the Supreme Court of Ohio, or any other
regulatory or judicial body.
Each signatory party agreed to withdraw any pending applications for
rehearing that it has filed in Pub. Util. Comm. Case Nos. 08-1094-
EL-SSO, et al. and 16-395-EL-SSO, et al. (relating to the ESP) and any appeals from
such proceedings upon approval of the stipulation without modification. Notably, IGS had previously moved for rehearing of an ESP order with respect to default service unbundling and supplier tariff and fee issues (story here)
Signatory parties agreed that the stipulation and ESP I satisfy the statutory requirements of R.C. 4928.143(E) (relating to reviews of ESPs exceeding three years) and that ESP I as currently implemented
passes the more favorable in the aggregate test and the prospective
significantly excessive earnings test in R.C. 4928.143(E).
Alternatively, signatory parties stipulated that if
the Commission finds that DP&L's ESP I fails to satisfy either prospective
test, then the Commission has the authority to approve, "the transition . . .
to the more advantageous plan."
"This Stipulation provides for an orderly
transition to such a plan, as DP&L has committed to filing a new ESP
application (ESP IV) by October 1, 2023 that will not contain charges as
identified [below]," the settlement stated
The stipulation provides that DP&L shall file an application for an electric security plan ('ESP IV') no
later than October 1, 2023 to replace ESP I.
Specifically, the adopted settlement provides that DP&L's ESP IV Application
shall not seek to implement any nonbypassable charge to customers
related to provider of last resort risks, stability, financial integrity, or any
other charge that is substantially calculated based on the credit ratings
debt, or financial performance of any parent or affiliated company of
"By way of example, the Signatory Parties agree that this
limitation does not prevent DP&L from proposing in the future riders that
recover actual costs that DP&L has incurred or will incur, distribution or
transmission related revenue that DP&L has foregone or will forego, or
distribution or transmission related investments (including a return on and
of the investments) that DP&L has made or will make. The Signatory
Parties are not precluded or in any way limited in challenging any
potential riders that DP&L may propose as part of any future proceeding," the stipulation stated
Solar Grant Payment To Retail Supplier Affiliate
The stipulation states, "In order to encourage the further development
of distributed and small generation facilities in accordance with R.C.
4928.02(C), after a Commission Order approving this Stipulation, DP&L
and IGS agree to work together to identify, select and then implement
solar project(s) that add up to at least 1.5 MW to be constructed in DP&L's
service territory ('the Solar Project(s)')."
"Within 90 days after IGS Solar,
LLC identifies the Solar Project location(s), DP&L will make a one-time
contribution in the amount of $1 million, to be funded by shareholder
dollars and not recovered through the IIR [Infrastructure Investment Rider] or other rates to IGS Solar, LLC
('the Solar Project Grant'). IGS Solar, LLC will apply the Solar Project
Grant toward design, construction, and deployment of the Solar Project(s),
which IGS Solar, LLC shall own and operate. DP&L shall have no
ownership interest in the Solar Project, and shall not be involved in its
operation," the stipulation states
Within 12 months after the Solar Project(s) are operational,
DP&L shall file a report in describing any distribution and/or
transmission costs saved or avoided as a result of the Solar Project(s).
Execution Of Third Party Apps By AMI Meters
The adopted stipulation contemplates the ability of Dayton Power & Light and third parties to use smart meters to execute apps for customers.
The stipulation states that an AMI meter with "Distributed Intelligence Capabilities"
is a meter that has an on-board computer with the capability
to download and execute software applications written by
DP&L or third parties. Distributed Intelligence
Capabilities do not refer to firmware that is loaded on an
AMI meter for basic operations.
The stipulation provides that, "At least 180 days before utilizing Distributed Intelligence
Capabilities of AMI meters during SGP [Smart Grid Plan] Phase 1, DP&L
will file a description of its planned utilization in the docket
for this proceeding to allow for public comment on that
plan by interested stakeholders. DP&L's filing will, at a
minimum, describe: (1) how third parties may be able to
utilize the AMI meter's Distributed Intelligence
Capabilities with appropriate customer consent, and under
what terms and conditions; (2) what customer services or
offerings DP&L may provide through the Distributed
Intelligence Capabilities of its AMI meters; and (3) a
description of what software applications have been, or are
planned to be, installed onto AMI meters."
Provision Of AMI Data To Retail Suppliers, Use In Settlement
As part of, and in the timeline
associated with, a new customer information system noted below, DP&L commits to the following:
i. The release of any customer's energy-usage data shall be in
accordance with the applicable North American Energy Standards
Board Energy Services Provider Interface standards and compliant
with all Ohio Administrative Code and Ohio Revised Code.
ii. DP&L shall provide Green Button Connect My Data ("GBC") for
use by any authorized CRES [Competitive Retail Electric Service provider] or third party on a non-discriminatory
basis to be completed as part of and in the timeline associated with
the CIS. GBC shall be independently tested and certified as
compliant with the latest standard as of time of release. DP&L is
not prohibited from supplementing or replacing GBC with a new
generally accepted industry standard Application Programming
Interface after collaborating with Staff, CRES, customers, and
third parties via the Grid Mod Implementation Update Group. The terms and conditions under which customer-authorized
CRES providers and third parties access GBC or any
other Application Programming Interface will be set forth in a DP&L
tariff subject to Commission approval.
iii. At a minimum, DP&L's GBC will provide, with appropriate
customer authorization, 24 months of historical usage data,
ongoing usage data, account number(s), meter identifier(s), and
customer billing determinants. For purposes of this provision,
"billing determinants" means customer-specific information used
to calculate a bill, including (if applicable to a given customer)
kilowatt-hours, kVAR, peak demand, and billing schedule, but
excluding non-customer-specific information contained in filed
tariffs. If DP&L determines in the future that billing determinants
are more expansive than this definition, DP&L will so inform the
Grid Mod Implementation Update Group to discuss inclusion in
Green Button Connect. As part of the Grid Mod Implementation
Update Group, DP&L will work with Staff, CRES and third parties
to further develop the types of data that may be shared through
GBC as well as the timelines and frequency of transmission.
iv. DP&L shall allow CRES providers to access the most current data
available for both prospective and existing customers through
GBC, with customer authorization as required. However, data for
purposes of billing and scheduling shall be provided via EDI or the
current standard form.
v. DP&L shall provide documented processes for registering,
troubleshooting and providing access to CRES providers and third
parties on a publicly available website. Any data from a customer
who objected to sharing data on the pre-enrollment list shall not be
provided without authorization.
vi. DP&L will make best efforts to: (i) operate the GBC platform with
an uptime of at least 99% during business hours as determined by
the Company and calculated on a monthly basis; (ii) respond
promptly to questions, issues or bugs raised by third parties and
seek to promptly resolve technical issues with the GBC platform;
and (iii) ensure that the data provided are accurate and up to date.
vii. Customer Experience. DP&L shall support the following
(1) DP&L will develop a process for CRES and third parties to
provide customer consent in accordance with Ohio
Adm.Code 4901:1-10-24 or any subsequent rule to access
data for prospective and existing customers. This process
will include the ability for customers to authorize the
release of energy usage data to CRES and third parties via
the following methods:
(a) DP&L's web site, which shall be optimized for the
Customer's screen size, or mobile app.
(b) Third party web site or mobile app (DP&L will not
be responsible for costs associated with developing
third party websites or mobile apps.) In this case,
DP&L will, for customers with a cellular telephone
number on file, send a text message one-time
passcode to the customer's cellular telephone to
complete the authorization.
(2) At the time of the request, the customer is prompted to
authenticate and authorize sharing of data and DP&L shall
require no more information of the customer than DP&L
requires for establishing an online account. Web-based
authentication and authorization must adhere to OAuth2.0
or a more recent industry-standard protocol as set forth at
https://oauth.net/2/. CRES and third parties should have
the option to determine the authorization term they require,
i.e. 12 months, 24 months, or indefinite ("valid until
rescinded"). DP&L will send notification to the customer's
preferred communication channel that DP&L has received
notification that the customer has authorized a third party
access to their customer energy usage data and/or account
number and provide instructions on how to contact DP&L
to cancel if they did not make such an authorization.
Customer will be notified annually of all CRES and third
parties that have current access to customer data and how to
rescind such access.
(3) Once authorized, DP&L will promptly begin transmission
of historical data within timely manner to a CRES or third
party. Subsequent to a successful Customer authorization,
when data is requested, the system will immediately or
nearly immediately process and return the requested data.
(4) DP&L shall support the authorization methods without
requiring the creation of an online account.
(5) DP&L shall provide a list of CRES and third parties that
have accessed the customer's data within the last six
months, which shall be prominently displayed and easily
accessible on the customer's on-line account and/or
With respect to individual wholesale market settlements, DP&L will facilitate wholesale
market settlements as part of and in the timeline associated with the CIS,
i. DP&L will make the necessary upgrades to systems and processes
for wholesale market settlements, i.e. calculating and settling
individual total hourly energy obligation ("THEO"), peak load
contribution ("PLC"), and network service peak load ("NSPL")
values for each customer, instead of relying on generic load
ii. DP&L shall transmit settlement data to PJM, at a minimum, in
iii. DP&L shall make the THEO, PLC, and NSPL data available to
authorized CRES providers, consistent with Ohio Adm.Code
4901:1-10-24 or any other subsequent rule, through the pre-enrollment
list and EDI transactions, as applicable. Customers will
also have access to this information.
DP&L will begin using AMI data for calculation of individualized
PLC when the necessary upgrades to systems have been made to
utilize the VEE certified AMI data that has been read for any
qualifying peak events. Until those upgrades have been completed
and an AMI meter has been installed, the current method of using
register reads and profiles will be used.
DP&L shall periodically update stakeholders on the progress toward data access for
product billing purposes.
DP&L shall share an updated map of where AMI is being deployed
with dates of deployment and an AMI tag on the Customer
Information List provided to CRES providers to indicate
Described as "Neutral Platform," the AMI deployment will utilize the necessary and
generally accepted standards, e.g., technologies to implement a Home
Area Network, so that customers can connect qualified devices (e.g., in-home
displays, smart programmable thermostats) to their meter, or
otherwise direct the meter to transmit usage data to any CRES or third
party selected by the customer. The technical eligibility requirements for
Home Area Network devices, if applicable, including those for security,
will be developed through the Grid Mod Implementation Update Group.
Qualified devices will not be limited to devices supplied only by the EDU
or an affiliate.
Through the term of SGP Phase 1, DP&L will update its G8 tariff such
that no fees shall be charged by DP&L to CRES or third parties associated
with accessing or requesting data, including but not limited to those set
forth in Tariff Sheet G8 page 29 A.1. (manual historical customer energy
usage) and A.2. (electronic interval meter data) ("Waived Fees"). DP&L
further agrees to forego recovery of the Waived Fees through the Infrastructure Investment Rider (IIR) or
future rate case. DP&L will track the number of requests for the manual
historical customer energy usage data and electronic interval meter data
and will estimate any associated labor.
New Customer Information System
DP&L will invest in, no later than 6
months after a Commission Order approving the stipulation, the
development of a new Customer Information System (CIS) that will perform core functionality, including at least
• Flexible pricing plans including CRES ability to bill for products that
utilize AMI data;
• The system will allow for CRES Electronic Data Interchange ('EDI') and
data access for billing and time-of-use product offers which use AMI
within three years after approval of the stipulation or in the timeline
associated with the CIS, whichever occurs first
• Meter to Cash process and bill presentment shall comply with all
applicable requirements of the Ohio Administrative Code and Ohio
• Integration of Integrated Voice Response, Customer Portal and Mobile
App, Advanced Metering Infrastructure, Advanced Distribution
Management System, Geographic Information System, Enterprise
Resource Planning System, Meter Asset Management System, Meter Data
Management System, and Mobile Workforce Management System
• Customer Relationship Management ("CRM") as a customer service and
Time Of Use Plan For Default Service Customers
The stipulation requires DP&L to propose a time-of-use ("TOU") SSO rate and implementation plan through an
EL-ATA case on a pilot basis during SGP Phase 1.
Any TOU rates that
are offered through DP&L's Standard Service Offer ("SSO") shall be
offered only on an "opt-in" basis. The generation related costs of any
TOU proposal shall remain fully bypassable, including costs associated
with the implementation, administration, or marketing of the Company's
TOU offering, which shall be deferred for
future recovery through SSO rates upon Commission approval.
DP&L is notified that there are at least three different suppliers offering
time-varying products utilizing AMI data, then DP&L, with Commission
approval, will request to withdraw its SSO TOU rate offering.
In a concurring statement, Commissioner Daniel R. Conway said that he, "strongly support[s]," the requirement for a TOU option for SSO customers
Furthermore, Conway stressed that while DP&L is obligated under the stipulation to request to withdraw its SSO TOU rate offering once competitive TOU offerings are available from at least three retail suppliers, such withdrawal remains subject to PUCO consideration and approval, and does not obligate PUCO to approve any request withdrawal of the SSO TOU rate offering
"I ... believe that we must encourage and support the
availability and realization of those benefits for all customers, including the SSO
customers. I am skeptical, however, that access for SSO customers to TOU rates should
be curtailed, and that type of rate should only be available to customers who take
generation service from competitive retail electric service (CRES) providers, once some
number of CRES providers offer a time-varying rate service. So, I write to make clear that
my view of Section 6.e. is that, by adopting that provision, we are in no way prejudging
the propriety of ending the SSO TOU rate once three CRES providers make a TVR
offering and DP&L has made the obligatory request to withdraw its SSO TOU tariff in
accordance with Section 6.e," Conway wrote
DP&L commits that it will not implement any form of prepay program as
part of the SGP Phase 1.
Bypassability Of Non-Market Transmission Charges
From the date of approval of the stipulation and continuing during
DP&L's current standard offer as approved by the Commission in its
December 18, 2019 Second Finding and Order in Case No. 08-1094-EL-SSO,
DP&L will re-open enrollment for the Transmission Cost Recovery Rider – Non-Bypassable (TCRR-N) Opt-Out Pilot Program
to signatory parties (including their members, affiliate members,
customers, or members' customers) to pass through the market price, and
peak hour billing, of the transmission system as described in DP&L's
Seventeenth Revised Sheet No. T8, and DP&L will work collaboratively
with manufacturing groups to target 50 manufacturers to participate.
TCRR-N recovers non-market based transmission (RTO) charges, and the opt-out allows such customers to assume such obligations themselves (or rather, their competitive retail supplier), rather than paying a nonbypassable charge for DP&L to assume such obligations.
DP&L shall, at least, propose to continue the TCRR-N Pilot for signatory
parties in DP&L's next ESP case. Prior to filing its next ESP, DP&L
further agrees to discuss with interested parties potential opportunities to
enhance the transmission pilot.
PIPP Water Heater Controller Pilot Program
Under the settlement, DP&L will issue a Request
for Proposals ("RFP") for a water heater controller Pilot within 60 days of
the installation of smart meters on at least 200 Percentage of Income Payment Plan ("PIPP") customer accounts
within the Dayton city limits.
The RFP will be for smart water heater
controllers to be installed on Percentage of Income Payment Plan
customers' electric resistive water heaters to reduce their peak load contribution ("PLC"). The goal of the Pilot will be to determine whether
reducing the PIPP customers aggregate PLC will create a better load
profile resulting in a better price for the PIPP auction.
The water heater
controllers will have two-way communication, a revenue grade metering
chip and two separate temperature probes to ensure accurate measurement
The RFP will be for an initial 60-day Pilot to prove the
concept of 200 water heater controllers with the potential to be expanded
to all PIPP customers with an electric resistive water heater, as smart
meters are installed.
The adopted stipulation reduces AMI investment to be recovered in the IIR during SGP Phase 1
from 100% of meters to 95%
The stipulation does not authorize under Phase I expenditures for DP&L's proposals for Distributed Energy Resources Management or Smart Community Demonstration Projects. See background on the proposals here
Case No. 18-1875-EL-GRD et al.