Rate Case Settlement Includes Supplier Consolidated Billing Collaborative -- EnergyChoiceMatters.com

Rate Case Settlement Includes Supplier Consolidated Billing Collaborative

Revised Terms For Brokers

Eliminates Switching Fee

September 19, 2022

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Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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A stipulation among certain parties in Duke Energy Ohio's electric rate case includes provisions for a supplier consolidated billing collaborative, elimination of the switching fee and other retail supplier tariff changes, and changes to the supplier tariff provisions applicable to brokers

Settling parties include Duke Energy Ohio, Inc.; Staff of the Public Utilities Commission of Ohio; Ohio Partners for Affordable Energy; Retail Energy Supply Association; Interstate Gas Supply Inc.; and Ohio Energy Group, among others. The Ohio Consumers' Counsel does not appear as a signatory party

The settlement provides that, within 60 days of approval of the stipulation without material modification, Duke Energy Ohio and IGS shall file a joint motion for an order bifurcating the supplier consolidated billing issues in Case Nos. 19-1750-EL-RDR, 19- 1751-GE-AAM, for consideration in a separate proceeding ("New Docket")

Within fourteen calendar days after the grant of the joint motion described above, Duke Energy Ohio will file in the New Docket a notification of a date by which it will convene an initial meeting to begin collecting the stakeholder input to prepare a report of recommendations of the parties concerning the implementation of supplier consolidated billing

The collaborative process shall include, at a minimum, discussions regarding, among other things:

• Reasonable program parameters and participation limitations (on customers or suppliers, as applicable) based upon the following issues:

i. The need to manage customers who shop for only gas or electric service, or both;
ii. What happens when the customer has different commodity suppliers for gas and electric services;
iii. What happens when the customer previously with the same supplier for both gas and electric either (a) reverts back to a standard service offer for only one of the commodities or (b) enrolls with a different supplier for only one of the commodities;

• Necessary consumer protections;
• Payment processing, including, but not limited to, purchase of utility receivables;
• An analysis of Duke Energy Ohio’s cost estimates for the implementation of supplier consolidated billing that include (among other provisions):

i. The stand-alone costs of the necessary system changes to implement supplier consolidated billing (a) exclusively for electric-only customers, (b) exclusively for natural gas-only customers, and (c) for all Duke Energy Ohio customers, including combination electric and natural gas customers;
ii. The cost of implementing supplier consolidated billing for any customer; and
iii. Technical feasibility and effort required for collections

Not later than 275 days after the first collaborative meeting, Duke Energy Ohio shall prepare and file the Report in the New Docket, based upon the consensus of the collaborative regarding the structure of a supplier consolidated billing program, if any, that should be considered by the Commission. Without limitation, the Report will provide an outline of the possible structure of supplier consolidated billing (i.e., gas, electric, or gas and electric customers), a schedule for the implementation of supplier consolidated billing, an estimate of the cost of implementing supplier consolidated billing, a proposed assignment of cost responsibility for system changes, and such other issues as the parties shall determine and shall include any dissenting opinions and recommendations.

Nothing in the stipulation shall be interpreted as Duke Energy Ohio or any other Signatory Party supporting the provision or implementation of supplier consolidated billing and all Signatory Parties shall reserve all rights to due process and ability to participate in the collaborative process and to support or oppose the concept of supplier consolidated billing for Duke Energy Ohio’s customers in the New Docket.

Supplier Fees

The Signatory Parties agree and recommend that within thirty days of approval of this Stipulation without material modification, Duke Energy Ohio shall amend its Certified Supplier Charges Tariff (Rate CS), Sheet No. 52 in its PUCO No. 20 Tariff, to (1) eliminate the End-use Customer Enrollment/ Switching Fee ($5.00/ switch); (2) eliminate the Customer Usage Request Charges ($6.00- One month of electronic Interval Meter Data and $7.50 – Twelve months of electronic Interval Meter Data); and (3) reduce from $150 to $50 the Pre-Enrollment End-use Customer Information List Fee.

The elimination of these fees in (1) and (2) shall eliminate the need to conduct any cost study for these costs as was previously agreed to as part of the settlement approved in Case No. 20-666-EL-RDR.

The settling parties said that the Company’s Customer Information System (CIS), live since April 2022, utilizes EDI transactions to complete enrollments and uses EDI transactions and the Company’s Supplier Portal to provide interval meter data to all electric suppliers. Given that there is no discernible incremental cost to any single EDI enrollment or any single customer interval data transaction (whether via EDI or the Supplier Portal), Signatory Parties agree that the cost of service study is no longer needed for these costs. The Company agrees to not seek future recovery for incremental costs related to transactions involving the data transfer associated with elimination of charges or enrollment EDI transactions or any single customer interval data query EDI transactions, unless future enhancements are authorized. Accordingly, the Signatory parties recommend that the Commission authorize the Company to forego its requirement to perform the cost of service study required by Paragraph 2 of the Stipulation approved in Case No. 20-666-EL-RDR.

All other fees contained in the Rate CS shall remain.

Supplier Tariff Applicability To Brokers

Within 30 days of approval of the stipulation without material modification, the Company will update its Supplier Tariff, PUCO No. 20, such that Power Brokers, as defined by O.A.C. 4901:1-24-01(S), shall be exempt from the following requirements listed below as long as (1) they maintain valid certification as Power Brokers with the Commission; (2) exclusively provide Power Brokerage services, as defined by O.A.C. 4901:1-24-01(T); (3) do not engage in any other Competitive Retail Electric Service activities listed in O.A.C. 4901:1-24-01(H); (4) do not conduct any "[c]ustomer enrollment" or "[c]ustomer billing" within the meaning of those two terms in O.A.C. 4901:1-10-29(F) and (G), respectively; and (5) do not seek to use EDI transactions to transact with Duke Energy Ohio:

1. Section 5.1(f) and (i) (requiring execution of EDI Trading Partner Agreement and completion of EDI testing respectively); and
2. Sections 6.2 to 6.5, inclusive (requirements related to establishing and maintaining creditworthiness, including but not limited to collateral).
3. Additionally, the Supplier Tariff, PUCO No. 20, Section 6.1 will be updated to specify that power brokers meeting all of the exemption criteria described above will only be required to complete the following fields in the Credit Application:

a. Section 1, Application/Contacts;
b. Section 2, Wiring (Bank Information);
c. Section 4, Bank Reference;
d. Section 5, Question I, Supplemental Data, PUCO Certification Number/ Expiration Date, Certification process;
e. Section 6, Representations;
f. Section 9, Certification, Authorization, and Signature;

Unbundling

Duke Energy Ohio agrees to withdraw its proposed Retail Reconciliation Rider (Rider RR) under the settlement.

The Retail Reconciliation Rider had been filed by Duke Energy Ohio in response to a PUCO order concerning the examination of the proper allocation of costs between generation and distribution service, as well as any costs incurred solely to support retail supplier choice

In filing the rider, Duke did not recommend adoption of the Retail Reconciliation Rider proposal, stating that the vast majority of base distribution costs are not related to the provision of generation service, other than a small amount of labor dollars that pertain to rate calculations and filings, settlements, and supplier support.

Under the settlement, Duke Energy Ohio agrees to file an application for the separation of default service costs from distribution rates to the extent the Revised Code is amended, or to the extent PUCO or state's Supreme Court specifically directs Duke to do so (PUCO or the Court directing a separate utility to perform such unbundling would not trigger any filing obligation from Duke)

Nothing in any of the above provisions shall be interpreted as precedent for any other proceeding or as an agreement by any Signatory Party as to the amount, types or categories of costs, if any, that should be separated from distribution rates. The Signatory Parties retain all rights to oppose such calculations and to oppose or support positions related to the separation of default service costs from base distribution rates at any court, the General Assembly, or the Commission.

Other Issues

Under the settlement, Duke Energy Ohio agrees to withdraw its proposal to amend its GoGreen Ohio rider (Rider GP), which is currently a program allowing customers to purchase blocks of RECs at a price set in the tariff.

Duke had proposed creating an option under the GoGreen Ohio rider for larger customers to negotiate a price for renewable energy credits (RECs) with the Company

The Company and Signatory Parties reserve their rights to propose, intervene, and participate in any future filings concerning GoGreen Ohio.

Duke agrees to revise its tariff such that Electric No. 19 Sheet No. 22.10 Section III – Customer Choice Enrollment and Participation Guidelines is clarified that the MDM Certified Meter Indicator and MDM Meter Certification Date should be added to the Pre-enrollment End-use Customer Information List.

Case No. 21-888-EL-ATA et al.

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