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PUC Approves Utility's Request To Suspend Retail Suppliers' Ability To Enroll New Customers, Change Rates, During Approximately Two Week CIS Cutover Period

PUC Addresses Issue Of Change In Customers' Account Number/Choice ID & Impact On Pending Enrollments With Legacy Number

March 23, 2022

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Copyright 2010-21
Reporting by Paul Ring •

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The Public Utilities Commission of Ohio approved Duke Energy Ohio's petition for waivers of certain Ohio rules as part of a cutover to a new CIS and billing system and the attendant cutover schedule, which includes periods in which retail suppliers will be unable to enroll customers or change rates in the CIS system

See background on Duke's proposal here, which had been exclusively first reported by

PUCO approved Duke's proposal, as clarified by various supplemental submissions, without substantive modification and with the caveats below

PUCO did not shorten the cutover period, or any of the specific "blackout" periods, as requested by some suppliers

As more fully discussed in our prior story linked above, enrollments in the choice program at Duke will be unavailable 3/19 to 4/6. From March 30 until April 6, 2022, Duke will suspend requests of CRES providers for customer-related transactions, such as changes in rate code, reinstatements, and historical usage requests

One of the primary issues raised by retail suppliers concerns a cross-reference list provided by Duke to suppliers to help suppliers match legacy customer accounts with the new service identifiers (new Choice Service ID)

PUCO ruled that the cross-reference list provided to suppliers should only include the supplier's existing customers, but also directed, for a limited period, that Duke shall work with suppliers via a manual process to facilitate enrollments in which the supplier has the existing legacy account for the customer, but not the new Choice Service ID

With regard to the cross-reference list, Duke had noted that it was amenable to provide a grace period during which Duke will work with suppliers to cross-reference individual customers manually. Duke further noted that it would need certain Commission rules waived to provide the Company with the ability to disclose customer account numbers to suppliers without the customer’s consent. Specifically, Duke stated that it would need waiver of Ohio Adm.Code 4901:1-10-24(E)(1) and (4) as well as Ohio Adm.Code 4901:1-13-12(D)(1) and (3), which are rules prohibiting electric and gas utilities from disclosing a customer’s account number without customer consent.

PUCO said that, to accommodate the cross-reference list and to facilitate a smoother transition for suppliers, the Commission waived the above rule provisions for 90 days, beginning April 5, 2022, the day Duke first intends to distribute cross-reference lists to suppliers.

"[I]n response to concerns regarding Duke’s plan to use a new Choice Service ID for each POD located at a customer’s premises, we direct the Company to work with suppliers to resolve any issues that arise on a case-by-case basis, in order to ensure that enrollments are processed correctly and as authorized by the customer," PUCO said

PUCO stressed that the cross-reference lists provided to suppliers will include only, "a supplier’s specific energy choice customers," and that the limited, manual process described above will apply to pending enrollments

"We note that the rule waiver is granted for the limited purpose of facilitating the manual cross-referencing process. We also agree with Staff and Duke that such cross-reference lists should include only a supplier’s specific energy choice customers," PUCO said

PUCO Staff and suppliers had requested that Duke provide a comprehensive plan that includes communications to customers and employees regarding the transition, and IGS requested such communications be approved by the Commission. Duke asserted that it has already been following such a plan and opposes the need for Commission approval of customer communications.

PUCO ruled that, "At this time, we do not find it necessary for the Commission to approve the planned customer communications, as generally outlined in Duke’s filings; however, as Duke agreed to in its surreply comments, we direct Duke to provide bi-weekly written updates to Staff on significant issues resulting from the waivers and conversion, along with any additional action that Duke will need to take to complete the conversion or assist customers. Further, we direct Duke to submit to Staff weekly written status updates on any significant billing errors, along with corrective actions. If a situation arises where Staff believes Commission attention is needed, then the Commission may intervene as necessary. Staff also requested that Duke convene regular, ongoing meetings with suppliers and provide dedicated Duke contacts to work through issues."

Duke plans to hold two supplier information sessions in April, one supplier information session in May, and one supplier information session in June.

As the Commission has directed Duke to keep Staff informed in the manner described above, and Duke has previously represented that it has contacts who are regularly available to suppliers who may have technical questions, PUCO found that Duke’s plan is reasonable

NRG Retail Companies has proposed that suppliers should not be penalized from customer complaints or have them counted against the supplier’s record if the complaints arise from the CIS transition itself.

In response, PUCO said, "We agree with Duke’s assessment that such complaints should be considered on a case-by case basis, and we will not provide absolution from complaints against suppliers arising during the conversion period, as IGS seems to request; however, we would certainly take into account the effect, if any, the conversion may have had in the circumstances leading to such a complaint."

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